revised total coliform rule for surface water …...september, 2013 revised total coliform rule for...

September, 2013

Revised Total Coliform Rule for

Surface Water Systems

NOTE: These slides may not match the recorded

presentation. To identify revised or new slides, on the

slide is noted “Updated Final” (revised) or “Clarification

Slide” (new) .

2

Disclaimer This presentation supplements the recorded webinar training

conducted by US Environmental Protection Agency (EPA) on

the Revised Total Coliform Rule (RTCR). The training provided guidance to States, Tribes, and EPA Regions that will have RTCR

primacy. These materials are not regulation s, nor do they

change or substitute for those provisions and regulations under

the RTCR. Thus, they do not impose legally binding

requirements. Further, the RTCR training materials do not

confer legal rights or impose legal obligations upon any

member of the public.

EPA made every effort to ensure the accuracy of the discussions presented in the webinar and presentation slides, but in the

event of a conflict between the discussions in these materials

and any statute or regulation, these webinars would not be

controlling.

3

RTCR Training Overview • Introduction • Sample Siting Plans

• Compliance Sampling

• Seasonal Systems

• Analyzing Samples

• Determining E. coli MCL Compliance

• Assessments & Corrective Actions

• Reporting and Recordkeeping

• Categories of RTCR Violations

• Public Notice (PN) & Consumer Confidence Report (CCR) Requirements

• Other Rule Aspects

• Summary

– Reference: TCR vs. RTCR Comparison

– Technical Corrections

4

About This Training Module

• While this training module specifically references “surface water systems,” this module applies to all public water systems (PWSs) that use: – Surface water (SW)

– Ground water under the direct influence (GWUDI) of SW

– SW or GWUDI blended sources that are required by the federal regulations to monitor monthly for total coliform.

• This set of systems is known as Subpart H systems.

5

Introduction

6

Contents of Introduction

• Training Goals

• Training Overview

• Available Resources

• Acronyms & Definitions

• Applicability

• RTCR Basics

• RTCR Purpose

• What Changed (& What Didn’t) From The TCR?

7

Training Goals

• Understand RTCR concepts & requirements

• Understand how RTCR keeps some aspects

of the TCR & replaces other portions

• Reinforce learning with polling questions

and quizzes

8

Training Overview

• SW training module includes: – SW training slides

– Supplemental Reference Materials: workshop/field examples; RTCR Quick Reference Guide (QRG)

• “Train-the-trainers” design

• Modify as appropriate

• Slides only cover federal requirements • NOTE: Total of 4 RTCR training modules

– Surface Water; Ground Water; Expanding Upon Level 1 And Level 2 Assessments And Corrective Actions; & State Primacy

9

RTCR Training Series

10

Training Icons

Important

Speaker Note

Customize

Animation

Regulators

Only

Same as TCR

Rule

11

Guidance Documents and Available Resources

• Planned for Release in 2013

– RTCR QRG (September)

– RTCR Assessments & Corrective Actions

Guidance Manual (November/December)

– RTCR State Implementation Guidance –

Interim Final (November/December)

12

Guidance Documents and Available Resources (cont.)

• Guidance Materials Planned for Release in 2014 – Draft Small Systems Guidance (Systems ≤ 1,000)

(Spring/Summer)

– Guide/Tool for Small NCWS Serving 1,000 or Less People (Fall/Winter)

– Factsheets (e.g., Seasonal Systems, Repeat Monitoring, L1 & L2 Assessments and Corrective Actions)

– Laboratory QRG/Factsheet

– Sampling Guide

– SDWIS Prime (formerly NextGen): Data Entry Instructions (DEI)

– Transition Memo

– Placards

Updated Final

13

Guidance Documents and Available Resources (cont.)

• Planned for Release in 2015-2016

– RTCR Articles

– Guide: Sanitary Surveys

– Update PN Handbook: Templates for TNCWS and Other Systems’ Handbook

– Update PN I-Writer for Small Systems

– Update PN Matrix Tool

– Update CCR State Implementation Guide Manual for NPDWRs

– Update Guidance for Preparing CCR

– Update CCR I-Writer

Acronyms

CWS Community Water System

EC+ E. coli-Positive

GW Ground Water

GWR Ground Water Rule

MCL Maximum Contaminant Level

NCWS Non-Community Water System

PN Public Notification

PWS Public Water System

RTCR Revised Total Coliform Rule

SW Surface Water

TC Total Coliform

TC+ Total Coliform-Positive

TCR Total Coliform Rule

TT Treatment Technique

Definitions

Public Water System (PWS)

Any entity that provides water for human consumption through pipes or other constructed conveyances to at least 15 service connections or serves an average of at least 25 people for at least 60 days a year.

Community Water System (CWS)

A PWS which serves at least 15 service connections used by year-round residents or regularly serves at least 25 year-round residents.

Subpart H System A PWS using SW or GW under direct influence of SW as a source.

40 CFR 141.2

Definitions (cont.)

Non-community Water System (NCWS)

A PWS that is not a CWS. A NCWS is either a “transient non-community water system (TNCWS)” or a “non-transient non-community water system (NTNCWS).”

Non-transient Non-community Water System (NTNCWS)

A PWS that is not a CWS and that regularly serves at least 25 of the same persons over 6 months per year.

Transient Non-Community Water System (TNCWS)

A NCWS that does not regularly serve at least 25 of the same persons over 6 months per year.

40 CFR 141.2

Definitions (cont.)

Consecutive System

A PWS that buys or otherwise receives some or all of its finished water from one or more wholesale systems.

Routine Monitoring

Normal TC sampling that must be conducted.

Repeat Monitoring

Follow-up sampling required when a compliance sample is TC+ (beyond routine monitoring).

40 CFR 141.2

New Definitions

40 CFR 141.2

Clean Compliance History

A record of no TCR or RTCR MCL violations, no TCR or RTCR monitoring violations, & no coliform TT trigger exceedances or TT violations.

Level 1 Assessment

An evaluation conducted by the system ( can be either operator or owner) to identify the possible presence of sanitary defects, defects in distribution system coliform monitoring practices, & (when possible) the likely reason that the system triggered the assessment.

Level 2 Assessment

A more detailed evaluation of a system conducted by an individual approved by the state with the same goals as a Level 1 assessment.

New Definitions (cont.)

Sanitary Defect

A defect that could provide a pathway of entry for microbial contamination into the distribution system or that is indicative of a failure or imminent failure in a barrier that is already in place.

Seasonal System

A NCWS that is not operated as a PWS on a year-round basis and starts up and shuts down at the beginning and end of each operating season.

40 CFR 141.2

20

MCL vs. TT

• Maximum Contaminant Level (MCL) =

highest allowable concentration of a

contaminant

– Compliance based on sampling results

• Treatment Technique (TT) = required process

intended to reduce the level of a

contaminant in drinking water

– Compliance based on performing activities

40 CFR 141.2; 141.52(a)(6) & 141.63(c)

21

RTCR Applicability

• Like 1989 TCR, RTCR applies to all PWSs

– Only microbial drinking water regulation that

applies to all PWSs

• SW & GW systems

• One of the few rules that applies to TNCWSs

• Any size PWS population

40 CFR 141.851(b)

22

General Description of RTCR

• Applies to all PWSs

• Replaces TCR’s TC MCL with TT requirements

• Replaces TCR’s acute TC MCL with an E. coli

MCL

• New requirements for seasonal systems

• TT requirements for PWSs vulnerable to

microbial contamination

40 CFR 141.851(b)-(c); 141.63(c), (d) & (e); 141.854(i)(1); 141.856(a)(4)(i); 141.859; 141.857(b); 141.854(c)(1); &

141.855(c)(1)

RTCR Timeline

RTCR Proposed Rule

2009 2010 2011 2012 2013 2014 2015 2016

SDWIS Prime Scheduled to be ready Sept. 2014

(Includes RTCR Compliance Determination)

RTCR Primacy Implementation

RTCR Final Rule

RTCR Implementation

Effective April 1, 2016

Updated Final

24

RTCR Purpose

• Improve public health protection by reducing fecal pathogens to minimal levels by controlling TC bacteria, especially E. coli

• TCR & RTCR objectives:

– Evaluate effectiveness of treatment

– Determine integrity of distribution system

– Signal possible presence of microbial contamination

• Cost-effective way to enhance multi-barrier approach to public health protection

25

Why Total Coliform & E. coli?

• RTCR uses TC & E. coli as indicators of potential risk – TC are a group of closely related bacteria that, with a

few exceptions, are not harmful to humans

– E. coli bacteria are a more accurate indicator of fecal contamination than TC, though not a measure of waterborne pathogen occurrence

• The presence of TC is a good indicator of a potential pathway of microbial contamination into the distribution system

• These contaminants could include: – Bacteria

– Viruses

– Parasitic protozoa

26

Types of RTCR Compliance Samples

• Routine samples:

– Required each monitoring period

• Repeat samples:

– Required for when a routine or repeat sample

is TC+

27

Special Purpose Samples

• Special purpose samples are operations-focused investigative samples that cannot be classified as routine or repeat compliance samples – Example: Samples used to determine if disinfection,

flushing, storage tank cleaning, etc. is working properly

• Samples required for repeat monitoring requirements are not special purpose samples & must be used to determine if a TT trigger exceedance or E. coli MCL violation occurred

• Extra routine samples taken per the sample siting plan are not special purpose & must be used to determine if a TT trigger exceedance or E. coli MCL violation occurred

40 CFR 141.853(a)(4) & (b)

28

Sample Siting Plans

29

Sample Siting Plan Basics

• Systems must develop and adhere to a

sample siting plan and a system-specific

schedule

– Must develop plans no later than March 31,

2016

• Sample siting plans are subject to state

review & revision

– States should review and determine whether

plans prepared by PWSs meet requirements of

the RTCR

40 CFR 141.853(a)

30

Sample Siting Plan Components

• Sampling locations

– Must be representative of the water in the distribution system

– Routine and repeat monitoring locations must be shown

– If applicable to GWR, must also show GWR sampling locations

• Sample collection schedule

– Samples must be collected at regular time intervals throughout the month

40 CFR 141.853(a)

31

Sampling Locations

• For SW systems, the sample siting plan must

include locations for:

– Routine samples

– Repeat samples

– If applicable to GWR, must also show triggered

source water sample locations

• Monitoring may take place at:

– Customer’s premises, OR

– Dedicated sampling station, OR

– Other designated compliance sampling location

40 CFR 141.853(a)(1) & (5)

32

Routine Monitoring

33

Number of Routine Samples

• Systems must collect at least the required number of routine samples – Even if the system has had an E. coli MCL

violation or has incurred a TT trigger

• Systems may take extra routine samples for public health protection and increased coverage of the distribution system – Must be taken in accordance with the sample

siting plan

– Must be representative of the distribution system

– Must be used in determining whether the TT trigger has occurred

40 CFR 141.853(a)(3) & 141.853(a)(4)

Updated Final

Monthly Routine Sample Table

• Number of routine monitoring samples does

not change from TCR

40 CFR 141.856(b) & 141.857(b)

TC MONTHLY MONITORING FREQUENCY FOR SW AND GWUDI SYSTEMS

Population Served Min # of Samples/Mo Up to 1,000 1

1,001 to 2,500 2 2,501 to 3,300 3 3,301 to 4,100 4 4,101 to 4,900 5 4,901 to 5,800 6 5,801 to 6,700 7 6,701 to 7,600 8 7,601 to 8,500 9



Population Served Min # of Samples/Mo 8,501 to 12,900 10

12,901 to 17,200 15 17,201 to 21,500 20 21,501 to 25,000 25 25,001 to 33,000 30 33,001 to 41,000 40 41,001 to 50,000 50 50,001 to 59,000 60 59,001 to 70,000 70 70,001 to 83,000 80

40 CFR 141.856(b) & 141.857(b) Updated Final

40 CFR 141.856(b) & 141.857(b)


Population Served Min # of Samples/Mo

83,001 to 96,000 90

96,001 to 130,000 100

130,001 to 220,000 120

220,001 to 320,000 150

320,001 to 450,000 180

450,001 to 600,000 210

600,001 to 780,000 240

780,001 to 970,000 270

970,001 to 1,230,000 300



Population served Min # of Samples/Mo

1,230,001 to 1,520,000 330

1,520,001 to 1,850,000 360

1,850,001 to 2,270,000 390

2,270,001 to 3,020,000 420

3,020,001 to 3,960,000 450

3,960,001 or more 480

40 CFR 141.856(b) & 141.857(b)


Small Systems Taking < 5 Routine Samples per Month

• The month following a TC+, systems serving

4,900 or fewer persons must sample at their

normal routine monitoring frequency:


Population served Min # of Samples/Mo Up to 1,000 1

1,001 to 2,500 2 2,501 to 3,300 3 3,301 to 4,100 4 4,101 to 4,900 5

40 CFR 141.21(b)(5); 141.856(b) & 141.857(b)

Small Systems Taking < 5 Routine Samples per Month (cont.)

• Monitoring requirements for systems serving

4,900 or fewer persons:

40 CFR 141.21(b)(5); 141.856(b) & 141.857(b)

TCR RTCR

Must take at least 5 routine samples in the month after a TC+ sample.

Systems must only take their usual number of samples the month following a TC+.

40

Routine Sample Table TC MONTHLY MONITORING FREQUENCY

FOR SYSTEMS WITH SW, GWUDI, or SW/GWUDI BLENDED SOURCES

Population Served Min # of

Samples/Mo Population Served

Min # of Samples/Mo

Up to 1,000 1 59,001 to 70,000 70

1,001 to 2,500 2 70,001 to 83,000 80

2,501 to 3,300 3 83,001 to 96,000 90

3,301 to 4,100 4 96,001 to 130,000 100

4,101 to 4,900 5 130,001 to 220,000 120

4,901 to 5,800 6 220,001 to 320,000 150

5,801 to 6,700 7 320,001 to 450,000 180

6,701 to 7,600 8 450,001 to 600,000 210

7,601 to 8,500 9 600,001 to 780,000 240

8,501 to 12,900 10 780,001 to 970,000 270

12,901 to 17,200 15 970,001 to 1,230,000 300

17,201 to 21,500 20 1,230,001 to 1,520,000 330

21,501 to 25,000 25 1,520,001 to 1,850,000 360

25,001 to 33,000 30 1,850,001 to 2,270,000 390

33,001 to 41,000 40 2,270,001 to 3,020,000 420

41,001 to 50,000 50 3,020,001 to 3,960,000 450

50,001 to 59,000 60 3,960,001 or more 480

Clarification Slide

41

Polling Question #1

42

TRUE OR FALSE: Under the RTCR: PWSs that use SW,

GWUDI, and SW or GWUDI blended sources and

have a TC+ result must collect additional routine

samples the following month.

A. True

B. False

Polling Question #1

43

Polling Question #1: Answer

TRUE OR FALSE: Under the RTCR: PWSs that use SW, GWUDI, and SW or GWUDI blended sources and have a TC+ result must collect additional routine samples the following month.

A. True

B. False

EXPLANATION: Subpart H systems maintain the same # of routine samples each month. Only eligible GW systems that monitor quarterly or annually are required to conduct 3 routine samples the month following a TC+ result.

Updated Final

44

Repeat Monitoring

Follow-up Monitoring for TC+ ROUTINE Sample(s)

• For every routine sample that is TC+: – Collect 3

repeat samples

• All TC+ samples must be tested for E. coli

40 CFR 141.858(a)(3) & 141.858(b)(1)

All routine TC+ samples must have 3 associated repeat samples

Within 24 hours

Site A

TC+

ROUTINE

SAMPLE(S)

Site A

TC-

Site B

TC-

Site C

TC- REPEAT

SET

Clarification Slide

Follow-up Monitoring for TC+ REPEAT Sample(s)

• For each routine TC+ sample, when there are multiple TC+ repeat samples in a set: – Collect one set of

3 repeat samples until either:

• TC are not detected in one complete set of repeats; OR,

• System determines that a TT trigger has occurred

40 CFR 141.858(a)(3)

Site A TC+

Repeat Set

1

Site C TC+

Site A TC-

Site B TC+

Site C TC-

Site A TC+

Site B TC+

Repeat Set

2

Site C TC-

Site A TC-

Site B TC-

Repeat Set

3

Within 24 hours

In this example, there are a total of 9

repeat samples.

Clarification Slide

47

Follow-up Monitoring for PWS Taking < 40

Total Compliance Samples/Month

• If there is a TC+ routine sample, where the

Round 1 repeat samples …

– Has one or more missing repeat samples,

then an assessment is triggered and

additional repeat samples are not required

– Has one or more TC+ or EC+ repeat samples,

then an assessment is triggered and additional repeat samples are not required

40 CFR 141.859(a)(1)(ii)

Number of Repeat Samples for Small Systems

• Small SW systems (serving ≤ 1,000 people) only

take 3 repeat samples

– 4 samples had been required under TCR

40 CFR 141.858(a)(1)

TCR RTCR

4 samples 3 samples

49

No Dual Purpose Samples: GWR and RTCR Repeat Samples

• Subpart H systems that are required to conduct

triggered GWR source water monitoring:

– Can no longer use repeat RTCR sample for both

GWR triggered source water monitoring and

repeat TC sampling

• Dual purpose samples are only available to GW

systems with a single well serving < 1,000

– With sample siting plan representative of water

quality in the distribution system, AND

– With written state approval

40 CFR 141.858(a)(1)

50

Repeat Sample Locations

• PWS can collect repeat samples using the same procedure as in the TCR

– 1 at original location

– 1 within 5 service connections upstream

– 1 within 5 service connects downstream

OR

• PWS can specify in their sample siting plan either fixed alternative locations or criteria for selecting sites on a situational basis via a standard operating procedure

40 CFR 141.853(a)(5)

51

Repeat Sample Locations (cont.)

• Systems can propose different repeat

monitoring locations to the state as long as

they are representative of a pathway for

contamination of the distribution system

40 CFR 141.853(a)(5)(i) & (a)(6)

52

Polling Question #2

53

Polling Question #2

At which of the following locations will your state require PWSs to conduct repeat monitoring?

A. 1 at the original location,1 within 5 service locations upstream, and 1 within 5 service locations downstream

B. Alternative locations identified by the system on a situational basis based on specific criteria

C. Allow both of the above options

States have discretion to allow both options

A and B

Repeat Monitoring

Deadline

• System has 24 hours after learning about TC+ routine sample to take repeat samples

• State may extend the 24-hour deadline (new deadline must be specified)

! TC+

Repeat 1 Repeat 2 Repeat 3 Within 24

hours

40 CFR 141.858(a)(1)

Repeat Monitoring Timing

• Must collect all repeats on same day

– 3 repeat samples are needed for each TC+

routine sample

• State may allow systems with single

service connection to:

– Collect over a 3-day period

– Collect a larger volume container(s) of any

size as long as the total volume collected

is at least 300mL

40 CFR 141.858(a)(1) & (2) Updated Final

Repeat Monitoring Scenario

• A routine sample is collected and before that first sample is analyzed, another routine sample is taken within 5 service connections

• The first sample is TC+

• The second routine sample can be counted as a repeat (instead of being counted as a routine sample)

• System needs to take another routine sample

40 CFR 141.858(a)(4)

1st Routine Sample ! TC+

2nd Routine Sample

1st Repeat

Sample

Updated Final

57

Disinfectant Residual Samples

• Under the Disinfection Byproduct Rules

(DBPRs) and Surface Water Treatment Rule

(SWTR):

– Must monitor disinfectant residuals at same

time and place as RTCR routine and repeat

samples

• Monitoring necessary to demonstrate

compliance with chlorine/chloramine MRDLs

and with SWTR requirement to maintain

detectable residual

40 CFR 141.132(c)(1)(i) & 141.74(b)(6)(i)

58

Seasonal System

Requirements

59

Seasonal Systems

• A seasonal system is a NCWS not operated as a

PWS on a year-round basis that starts up/shuts

down at the beginning & end of each operating

season

• State may exempt seasonal systems from

requirements for seasonal systems if the

distribution system remains pressurized during the entire period that the system is not operating

– Systems are still required to meet monitoring

requirements, as designated by the state

40 CFR 141.2

Updated Final

60

Requirements for Seasonal Systems with SW/GWUDI Sources

• Must monitor monthly for all months they are in operation (No exemption from monthly monitoring)

– No quarterly or annual monitoring allowed for systems using SW/GWUDI or SW/GWUDI blended sources.

• Must follow a state-approved start-up plan

– State may exempt system from start-up requirements only if the distribution system remains pressurized during the entire period that the system is not operating

40 CFR 141.856(a)(4) & 141.857(a)(4)

Clarification Slide

Routine Sampling Exercise • Complete the table:

Routine Sampling for Magnificent Park Water System NTNCWS, GWUDI, Shutdown Period: Oct - Feb

Month Population Served # of Routine RTCR

Samples Required

March 40

April 40

May 40

June 3375

July 3375

August 40

September 40

Routine Sampling Exercise: Answer

Routine Sampling for Magnificent Park Water System NTNCWS, GWUDI, Shutdown Period: Oct - Feb

Month Population Served # of Routine RTCR

Samples Required

March 40 1

April 40 1

May 40 1

June 3375 4

July 3375 4

August 40 1

September 40 1

Updated Final

63

Start-up Procedures

• States have the flexibility to determine what

start-up procedures are appropriate for a

particular system based on site-specific

considerations

• States may require one or more TC samples

as part of the required start-up procedures

40 CFR 142.16(q)(2)(vii); 141.856(a)(4)(i) & 141.857(a)(4)

64

Seasonal System Violations

• TT violations

– Failure to complete state-approved start-up

procedures prior to serving water to the

public

• Reporting violations

– Failure to submit certification of completion of

start-up procedures

40 CFR 141.860(b)(2) & (d)(3)

65

Polling Question #3

66

TRUE OR FALSE: Failure by a non-community

seasonal system to complete state-approved

start-up procedures prior to serving water to the

public is a TT violation.

A. True

B. False

Polling Question #3

Updated Final

67

TRUE OR FALSE: Failure by a non-community

seasonal system to complete state-approved

start-up procedures prior to serving water to

the public is a TT violation.

A. True

B. False


Updated Final

68

Polling Question #4

69

Polling Question #4

Which of the following is your state considering as requirements for seasonal systems’ start-up procedures? (Select all that apply):

A. Disinfection and flushing

B. Sampling for total coliform/E. coli

C. Minimum disinfectant residual in distribution system

D. Site visit by state or state-approved third party

E. Verification that any current or historical sanitary defects from previous operational period have been corrected

States have discretion to allow any combination of these procedures or additional procedures

not listed here.

Updated Final

70

Polling Question #5

71

What is the RTCR monitoring frequency for

seasonal systems that use SW/GWUDI, or year-

round SW blended sources?

A. Monthly

B. Quarterly

C. Annually

Polling Question #5

72


What is the RTCR monitoring frequency for seasonal systems that use SW/GWUDI, or year-round SW blended sources?

A. Monthly

B. Quarterly

C. Annually

EXPLANATION: All Subpart H systems, including seasonal systems are required to monitor monthly when in operation under the RTCR.

Updated Final

73

Analyzing Samples

74

Analyzing for TC vs. E. coli

• All TC+ routine or repeat samples must be tested for E. coli

• State can allow a system to forgo E. coli testing on a TC+ sample if the system assumes the sample is EC+

– Case-by-case basis

– EC+ assumption must still be reported the same day or next day to the state

– System incurs an E. coli MCL violation, is required to conduct a Level 2 assessment, and comply with PN/CCR requirements

40 CFR 141.858(b)

Updated Final

75

Certified Laboratories

• Samples must be analyzed by an EPA- or

state-certified drinking water lab

• Labs must be certified for each method used

for analysis & each contaminant analyzed

40 CFR 141.852(b)

76

Analytical Requirements

• Standard sample volume required for analysis = 100 mL

– Regardless of analytical method

• Only determining presence or absence of total coliform & E. coli is required

• The time from sample collection to initiation of test medium incubation may not exceed 30 hours

• If residual chlorine present, sodium thiosulfate must be added

40 CFR 141.852(a)(1)-(3)

Updated Final

Total Coliform Analytical Methods

40 CFR 141.852(a)(5)

Methodology Category

Methods

Lactose Fermentation Methods

• Standard Methods 9221B - Standard Total Coliform Fermentation Technique

• Standard Methods 9221D - Presence-Absence (P–A) Coliform Test

Membrane Filtration Methods

• Standard Methods 9222B – Standard Total Coliform Membrane Filter Procedure

• MI medium • m-ColiBlue24® Test • Chromocult

Enzyme Substrate Methods

• Colilert® • Colisure® • E*Colite® Test

• Readycult® Test • Modified Colitag® Test

E. coli Analytical Methods

40 CFR 141.852(a)(5)

Methodology Category Methods

Escherichia coli Procedure (following Lactose Fermentation Methods)

• Standard Methods 9221 F - EC–MUG medium

Escherichia coli Partition Method

• Standard Methods 9222G - EC broth with MUG (EC–MUG)

• Standard Methods 9222G - NA–MUG medium

Membrane Filtration Methods

• MI medium • m-ColiBlue24® Test • Chromocult

Enzyme Substrate Methods • Colilert® • Colisure® • E*Colite® Test

• Readycult® Test • Modified Colitag®

Test

Invalidation of Samples

40 CFR 141.853(c)

• Invalidated samples cannot be used to determine if the system had an E. coli MCL violation or TT trigger

• Re-samples must be taken at

same locations and used for

compliance calculations

New sample

in 24 hours

Documentation of

Sample

Invalidation

Rationale for

invalidation Cause of TC+ Action to

correct problem

State Signature

Updated Final

80

Invalidation of Samples (cont.)

• State may invalidate a sample if:

– Lab establishes that improper sample analysis caused the TC+

– State determines from repeat sample results that the TC+ was caused by domestic or other non-distribution system plumbing problem

– State finds that the TC+ is a result of something that does not reflect water quality in the distribution system

40 CFR 141.853(c)(1)

Systems must collect replacement samples for all

invalidated samples!

81

Polling Question #6

82

Polling Question #6

Does your state have an after-hours phone line or alternative notification procedure for systems to

use if they become aware of an E. coli MCL

violation or EC+ sample after the state office is

closed?

A. Yes

B. No

83

Assessments

84

Purpose of Assessments

• All systems required to conduct an assessment

when monitoring results show that the system

may be vulnerable to contamination

• An assessment is an evaluation to identify sanitary defects & TT triggers

• More proactive approach to public health

protection compared to TCR

– Conditions that defined a non-acute MCL

violation under TCR are now used to trigger

assessment

40 CFR 141.859(a)-(b)

85

Sanitary Defects

• Sanitary defect: a defect that could provide

a pathway of entry for microbial

contamination into the distribution system or

that is indicative of a failure or imminent

failure in a barrier that is already in place,

e.g.,

– Holes in storage tanks

– Breaks in pipes

– Cracks in well seals or casings

40 CFR 141.2

86

Elements of Assessments

• At a minimum, assessment must include review & identification of the following elements: – Atypical events that may affect distributed water

quality or indicate that distributed water quality was impaired

– Changes in distribution system maintenance & operation that may affect distributed water quality, including water storage

– Source & treatment considerations that bear on distributed water quality

– Existing water quality monitoring data

– Inadequacies in sample sites, sampling protocol, & sample processing

40 CFR 141.859(b)(2)

87

Conducting Assessments

• Must be conducted: – Consistent with state directives

– As soon as practical after the system learns it has triggered an assessment

• Assessment form must be submitted to state within 30 days after system learned it triggered assessment

• Assessment form must include: – Assessments conducted

– All sanitary defects found (if any)

– Corrective action(s) completed and/or proposed timetable for correction actions not yet complete

• Failure to conduct an assessment or correct sanitary defects is a TT violation and requires Tier 2 PN

40 CFR 141.859(b)(3)-(4) & 141.860(b)(1)

88

Level of Effort – Level 1 vs. Level 2

• Level 1:

– Conducted by the PWS

– Primarily completed using existing data

– May include limited inspections or interviews

• Level 2:

– More comprehensive review of existing data

– May include field investigations, additional sampling, and inspections

– May involve consultation with additional parties

– Assessment must be conducted by the state or party approved by the state

89

Level 1 Assessments

Level 1 Assessment Triggers

Fail to take all required repeat samples after

any TC+

Level 1 assessment

≥ 40 Samples

> 5.0% TC+

Within 1

month

< 40 Samples

≥ 2 more TC+

40 CFR 141.859(a)(1)

Must consider all samples (the total number of

routine and repeat) to determine Level 1

assessment trigger

Clarification Slide

91

Polling Question #7

92

Polling Question #7

Early in the month, a water system has triggered a

Level 1 assessment. Is the system allowed to skip

collecting the remaining RTCR routine samples for that month?

A. Yes

B. No

93


Early in the month, a water system has triggered a Level 1 assessment. Is the system allowed to skip collecting the remaining RTCR routine samples for that month?

A. Yes

B. No

EXPLANATION: A system must still take the required minimum number of routine samples even if it has had an E. coli MCL violation or has exceeded the coliform treatment triggers before the end of the monitoring compliance period.

Updated Final

94

Who Conducts Level 1 Assessments?

• Intended to be self-assessments

• Systems may receive assistance from states

– PWS may conduct assessment while consulting with state via phone

– State may fill out assessment form during phone consultation with PWS

– Either the PWS or state can at any time consult with the other party to discuss the assessment or corrective action(s)

– States may set up alternative methods for form submission

95

Completed Level 1 Assessment Form Components

• Must include:

– Sanitary defect(s) identified

• Assessment form may note that no sanitary

defects were identified, if applicable

– Corrective actions taken

– Proposed timetable for corrective actions not

yet completed

40 CFR 141.859(b)

Submission & Review

• State will review assessment to determine if:

– System identified likely cause of Level 1

trigger

– System corrected the problem or has an

acceptable schedule for correction

40 CFR 141.859(b)(3)(iii)

Within 30 days of

learning that trigger

has been exceeded

Submit completed Level 1

assessment form to state

Updated Final

97

Level 2 Assessments

Level 2 Assessment Triggers

• Considering all compliance samples (routine and repeat) a system has:

– A second Level 1 trigger within a rolling 12-month period

• Unless the state has determined a likely reason that the samples that caused the first Level 1 TT trigger were TC+ and has established that the system has corrected the problem

– An E. coli MCL violation

40 CFR 141.859(a)(2)

E. coli MCL violation

Level 2 assessment

Two Level 1 triggers

12 rolling months

Clarification Slide

99

Who Conducts Level 2 Assessments?

• Must be conducted by state-approved party

– The state

– A third party approved by the state, including

PWS staff, if qualified

• Must follow state directives related to:

– Size & type of system

– Size, type, & characteristics of distribution

system

40 CFR 141.859(b)(2) & 141.859(b)(4)(i)-(ii)

100

Completed Level 2 Assessment Form Components

• Level 2 assessment elements contain the

same elements as the Level 1, but each

element is investigated in greater detail

• Must include:

– Sanitary defect(s) identified

– Corrective actions

– Timetable for corrective actions

40 CFR 141.859(b)(4)(i)

101

Submission & Review

• State will review assessment to determine if:

– System identified likely cause of Level 2 trigger

– System corrected the problem or has an

acceptable schedule for correction

40 CFR 141.859(b)(4)(iv)

Within 30 days of

learning that trigger

has been exceeded

Submit complete Level 2

assessment form to the state

Updated Final

102

TT Violations Associated with a Level 1 and Level 2 Assessment

• PWS fails to perform assessment(s) or

corrective action(s) within the required

timeframe

– TT violation: failure to perform Level 2

assessment or corrective action(s)

40 CFR 141.860(b)(1)

Updated Final

103

Polling Question #8

104

Polling Question #8

Does your state plan on approving SW systems

to conduct their own Level 2 assessments?

– Yes

– No

– Undecided

States have discretion to allow water systems to conduct their own Level 2 assessment.

105

Polling Question #9

106

Polling Question #9

Over 5.0% of the RTCR samples at Daphne’s

water system are TC+. However, one routine

sample TC+/EC+ and its associated repeat

sample is TC+. Daphne is required to collect

100 samples/mo.

What type of assessment is required?

A. Level 1

B. Level 2

107


Over 5.0% of the RTCR samples at Daphne’s water system are TC+. However, one routine sample TC+/EC+ and its associated repeat sample is TC+. Daphne is required to collect 100 samples/mo.

What type of assessment is required for the month?

A. Level 1

B. Level 2

EXPLANATION: This system has an E. coli MCL violation, which triggers a Level 2 assessment.

Updated Final

108

Polling Question #10

109


Over 5.0% of the RTCR samples at Prince George’s water system are TC+. However, the system only has one EC+ routine sample which is associated with a repeat TC- result. All of the other repeat samples for the month are EC-. Prince George’s is required to take 210 routine samples each month.

What type of assessment is required? (Select all that apply)

A. Level 1

B. Level 2

Updated Final

110

Polling Question #10: Answer Over 5.0% of the RTCR samples at Prince George’s water system are TC+. However, the system only has one EC+ routine sample which is associated with a TC- result. All of the other repeat samples for the month are EC-. Prince George’s is required to take 210 routine samples each month.

What type of assessment is required?

EXPLANATION: A Level 1 assessment is triggered if this is not the second trigger for a Level 1 in the previous 12 rolling months. A Level 2 assessment is triggered if this is the second Level 1 assessment within the previous 12 rolling months, unless the state has determined the reason for the first Level 1 and that the system has corrected the problem.

Updated Final

111

Corrective Actions

Associated with Level 1

and Level 2 Assessments

112

Timing of Corrective Action

• System must complete corrective action:

– By the time assessment form is submitted, which is within 30 days of the trigger

– OR

– Within state-approved timeframe

• System must notify the state when each scheduled corrective action is completed

• Either system or state can at any time request a consultation with the other party to discuss the corrective action

40 CFR 141.859(c)-(d)

113

Common Corrective Actions

• Disinfection

• Flushing

• Replacement/repair of distribution system or

storage components

• Storage facility maintenance

• Development/implementation of operations

plan

• Maintenance of adequate pressure

• Training on proper sampling technique

Common Causes of Contamination & Corrective Actions

Common Cause Common Corrective Action(s)

Failure to disinfect (or improper disinfection) after maintenance work in the distribution system

• Disinfection

Main breaks • Disinfection • Replacement/repair of

distribution system components

Holes in storage tank, inadequate screening, etc.

• Replacement/repair of distribution system components

• Maintenance of storage facility • Addition of security measures • Development & implementation

of an operations plan

Common Causes of Contamination &

Corrective Actions (cont.)

Common Cause Common Corrective Action(s)

Loss of system pressure • Maintenance of adequate pressure • Valve maintenance • Addition or upgrade of on-line monitoring

& control

Biofilm accumulation in the distribution system

• Flushing • Maintenance of adequate pressure

Cross connections • Maintenance of adequate pressure • Installation of backflow prevention

assembly/device • Implementation/upgrade of cross

connection control program

Common Causes of Contamination &

Corrective Actions (cont.)

Common Cause

Common Corrective Action(s)

Inadequate disinfectant residual

• Disinfection • Flushing • Maintaining appropriate hydraulic residence time • Addition or upgrade of on-line monitoring & control

Contaminated sampling taps

• Replacement/repair of distribution system components

• Sampler training

Sampling protocol errors

• Sampler training • Development & implementation of an operations

plan

117

Categories of RTCR

Violations

118

Violations Under the RTCR

• E. coli MCL violation

• TT violations

• Monitoring violations

• Reporting violations

A “Level 1 or Level 2 assessment trigger” is not

a violation type. There is not a violation type

for a “Level 1 or Level 2 assessment trigger”.

40 CFR 141.860

Clarification Slide

119

Compliance Possibilities

• 2 primary compliance tracks

– E. coli MCL

• More specific indicator of fecal contamination

– TT based on assessment

• Assessment (Level 1 or 2) identifies sanitary

defect(s)

• Corrective actions identified to address

sanitary defect(s)

• System must implement corrective actions

• Completing these steps is the TT requirement

40 CFR 141.63 & 141.859

E. coli MCL Violation

A PWS is in violation of the E. coli MCL when

any of these conditions occur:

40 CFR 141.860(a)

E. coli MCL Violation Occurs with Any of These Sampling Result Combinations

ROUTINE REPEAT

EC+ TC+

EC+ Any missing repeat sample

TC+ EC+

TC+ TC+ (but no E. coli analyzed)

Clarification Slide

121

Treatment Technique Violations

• A PWS is in violation of the RTCR TT when any of the following occur:

– Failure to conduct a Level 1 or Level 2 assessment within 30 days of trigger

– Failure to correct all sanitary defects from a Level 1 or Level 2 assessment within 30 days of trigger or in accordance with a schedule acceptable to the state

– Failure for a seasonal system to complete state-approved start-up procedure prior to serving water to public

40 CFR 141.860(b)

Clarification Slide

122

Monitoring Violations

• The following two types of monitoring failures

are monitoring violations:

– Failure to take routine total coliform sample

– Failure to analyze for E. coli following a TC+

routine sample

• NOTE: Not every failure to monitor is

considered a monitoring violation! Please

see CFR.

40 CFR 141.860(c)

Clarification Slide

Monitoring Failures

40 CFR 141.859(a)(1)(iii) & 141.860(c)

Description Monitoring

Violation

E. coli

MCL

Violation

Triggers Level 1 or

Level 2

Assessment

Failure to take routine sample Yes

Failure to take/analyze for E. coli

following a TC+ routine sample Yes

Failure to take repeat samples

following a TC+ routine sample

Triggers Level 1

assessment*

Failure to take repeat sample

following an EC+ routine sample Yes

Failure to take/analyze for E. coli

following a TC+ repeat sample Yes

* A Level 2 assessment is triggered if a second Level 1 assessment was

triggered within a rolling 12-month period.

Clarification Slide

124


125


FILL IN THE BLANK: Failure to take repeat RTCR

samples following a routine EC+ sample is a

______

A. Monitoring violation

B. E. coli MCL violation

C. Level 1 assessment trigger

126


FILL IN THE BLANK: Failure to take repeat RTCR

samples following a routine EC+ sample is a

______

A. Monitoring violation

B. E. coli MCL violation

C. Level 1 assessment trigger

Updated Final

127


128


Failure to take repeat samples following a

routine total coliform-positive/E. coli-negative

sample_______ (select all that apply)

A. Causes a monitoring violation

B. Triggers a Level 1 assessment

C. Triggers a Level 2 assessment

129


Failure to take repeat samples following a routine total coliform-positive/E. coli-negative sample_______(select all that apply)

A. Causes a monitoring violation

B. Triggers a Level 1 assessment

C. Triggers a Level 2 assessment

EXPLANATION: A Level 1 assessment is triggered if this is not the second trigger for a Level 1 in the previous 12 rolling months. A Level 2 assessment is triggered if this is the second Level 1 assessment within the previous 12 rolling months, unless the state has determined the reason for the first Level 1 and that the system has corrected the problem.

Updated Final

130

Pop Quiz

131

Quiz

FILL IN THE BLANK: If a PWS fails to analyze for E.

coli following a TC+ routine sample, the PWS

has incurred a ___?___ violation. If a PWS fails

to analyze for E. coli following a TC+ repeat

sample, the PWS has incurred a ___?___

violation.

132

Quiz: Answer

FILL IN THE BLANK: If a PWS fails to analyze for E.

coli following a TC+ routine sample, the PWS

has incurred a MONITORING violation.

If a PWS fails to analyze for E. coli following a

TC+ repeat sample, the PWS has incurred an

E. coli MCL violation.

Updated Final

133

Reporting and

Recordkeeping

Requirements

Reporting Requirements – RTCR

Systems must report to the state:

REQUIREMENT TIMING

E. coli MCL violation, or

EC+ routine sample

By end of current business day

(or next business day if state

office is closed)

TT violation By end of next business day

Level 1 or 2 assessment

report

Within 30 days of learning that

the system has exceeded a TT

trigger

40 CFR 141.861(a)(1)-(3)

Reporting Requirements (cont.)

Systems must report to the state:

REQUIREMENT TIMING

Coliform monitoring violation Within 10 days of learning of

violation

Completion of corrective action, if

occurring after submittal of an

assessment report

When each corrective action is

completed

Seasonal system certification of

compliance with state-approved

start-up procedures

Prior to serving water to the

public

40 CFR 141.861(a)(3)-(5)

136

Reporting Violations

• Failure to submit monitoring report or

completed assessment form

• Failure to notify the state of a routine or

repeat EC+ sample in a timely manner

• Failure to report completion of corrective

action

• Seasonal systems

– Failure to submit certification of completion of

start-up procedures

40 CFR 141.861(d)

Updated Final

PWS Recordkeeping

40 CFR 141.33(a)-(c) & (f)

PWSs must maintain records:

REQUIREMENT TIMING

Records of action taken by the system to

correct violations of primary drinking water

regulations

3 years

Public notices issued & certifications made 3 years

Records of microbiological analysis 5 years

Copies of monitoring plans As long as analyses

are required

PWS Recordkeeping (cont.)

PWSs must maintain records:

REQUIREMENT TIMING

Level 1 or 2 assessment forms 5 years

Documentation of corrective actions 5 years

Other available summary documentation of sanitary

defects & corrective actions

5 years

Records of any repeat samples taken that meet the

state’s criteria for an extension of the 24-hour period

for collecting repeat samples.

5 years

40 CFR 141.861(b)

State Recordkeeping

40 CFR 142.14(a)(1) & 142.14(a)(10)(i)

States must maintain records:

REQUIREMENT TIMING

Microbiological analyses 1 year

Decisions to waive the 24-hour time limit for collecting repeat samples after a TC+ routine sample or sample invalidation

5 years

Decisions for unfiltered SW systems to collect a TC sample following a turbidity measurement >1 NTU

Decisions to waive the requirement for 3 routine samples the month following a TC+ sample

Decisions to invalidate a TC+ sample

Completed & approved Level 1 or 2 assessments

Reports from systems of completed corrective actions

Updated Final

State Recordkeeping (cont.)

40 CFR 142.14(a)(10)(ii)(D)

States must maintain records:

REQUIREMENT TIMING

Decisions to allow a system to forgo E. coli testing of a TC+ sample if that system assumes that the sample is EC+

In such a manner that each system’s current status may

be determined

141

Reporting Violations

• A PWS is in violation of reporting requirements when any of the following occurs: – Failure to submit monitoring report

– Failure to submit a completed Level 1 or Level 2 assessment form within 30 days of learning of the trigger

– Failure to notify the state by the end of the next business day following an EC+ sample or E. coli MCL violation

– Failure for a seasonal system to timely submit certification of completion of state-approved start-up procedure (prior to serving water to the public)

40 CFR 141.860(d)

Updated Final

PWS Compliance Guide

40 CFR 141.859(a) & 141.860(a)

Sample Type Result Required

Assessment

Monitoring

Next Steps ROUTINE REPEAT E. coli

MCL Violation

EC+ TC+

Yes Level 2

For every TC+

routine sample

result, collect set

of 3 repeat

samples

TC+ EC+

EC+ Any missed

TC+ TC+

(no E. coli taken)

*TC+ Any missed No Level 1**

** The system must conduct a Level 2 assessment (instead of a Level 1 assessment) if Level 1 assessment already triggered within the past rolling 12-month period.

*Disclaimer: This is summary information and is not comprehensive of Level 1 assessment triggers and follow-up monitoring requirements for TC+ repeat samples. Please see CFR for additional information.

Clarification Slide

Updated Final

143

Public Notification &

Consumer Confidence

Report Requirements

Tier 1 & 2 PN Requirements

40 CFR 141.63(c); 141.201; 141.860(a)-(b); & Appendix A to Subpart Q –IA.1.b; IA.2.b & IA.2.c

Tier Violation

Tie

r 1

Has an EC+ repeat sample following TC+ routine sample

Has TC+ repeat sample following an EC+ routine sample

Fails to take all required repeat samples following an EC+ routine sample

Fails to test for E. coli when any repeat sample is TC+

Tie

r 2

TT violation resulting from failure to perform Level 2 assessment or corrective action

TT violation resulting from failure to perform Level 1 assessment or corrective action

Failure of non-community seasonal systems to complete state-approved start-up procedure prior to serving water to the public

Tier 3 PN Requirements

40 CFR 141.860(c) & (d) & Appendix A to Subpart Q – I.A.1.b & I.A.2.b

Tier Violation

Tie

r 3

Monitoring Violations:

Failure to take every required routine or additional routine sample.

Failure to analyze for E. coli following a TC+ routine sample.

RTCR Reporting Violations:

Failure to submit a monitoring report or completed assessment form after a system properly conducts monitoring or assessment in a timely manner.

Failure to notify the state following an EC+ sample in a timely manner.

Failure to submit certification of completion of state-approved start-up procedure by a seasonal system.

Tier 1 PN Requirement

• E. coli MCL violation = Tier 1 PN

• Repeat notices: timing, form, manner, frequency,

and content established by the primacy agency

• Systems must comply with any additional PN

requirements

40 CFR 141.202(a)-(b)

Within 24 hours

of violation

Issue Tier 1 PN (with modified standard health effects language)

Consult Primacy Agency


• No monthly E. coli MCL violation

• TT violations = Tier 2 PN

40 CFR 141.203(a)-(b)

Issue Tier 2 PN

(with modified standard

health effects language) Within 30 days of

learning of violations

Every 3 months that

problem persists

Repeat notice

Updated Final


• Monitoring violations and reporting violations

Within 1 year of

violation

Issue Tier 3 PN*

Every 12 months that

problem persists

Repeat notice Can be detailed

in CCR

40 CFR 141.204

* Tier 3 PN can be issued in the CCR if it is distributed within 12 months of the violation.

149


150


• Tier 3 PN is required for which of the following reporting violations? (Select all that apply)

– Failure to submit a monitoring report or completed assessment form in a timely manner after the PWS has properly conducted monitoring or an assessment.

– Failure to notify the state in a timely manner following an EC+ sample, as required by 40 CFR 141.858(b)(1).

– Failure to submit certification of completion of state-approved start-up procedure by a seasonal NCWS.

151


• Tier 3 public notification is required for which of the following reporting violations? (Select all that apply)

A. Failure to submit a monitoring report or completed assessment form in a timely manner after the PWS has properly conducted monitoring or an assessment.

B. Failure to notify the state in a timely manner following an EC+ sample, as required by 40 CFR 141.858(b)(1).

C. Failure to submit certification of completion of state-approved start-up procedure by a seasonal NCWS.

Updated Final

Health Effects Language

40 CFR 141 Appendix B to Subpart Q –1g

E. coli MCL Violation

Tie

r 1

“E. coli are bacteria whose presence indicates that the water may be contaminated with human or animal wastes. Human pathogens in these wastes can cause short-term effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a greater health risk for infants, young children, the elderly, and people with severely compromised immune systems.”

Health Effects Language (cont.)

40 CFR 141 Appendix B to Subpart Q –1f

TT Violations (Assessment Triggered By Presence Of E. coli)

Tie

r 2

“Coliforms are bacteria whose presence indicates that the water may be contaminated with human or animal wastes. Human pathogens in these wastes can cause short-term effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a greater health risk for infants, young children, the elderly, and people with severely compromised immune systems. We violated the standard for E. coli, indicating the need to look for potential problems in water treatment or distribution. When this occurs, we are required to conduct a detailed assessment to identify problems and to correct any problems that are found.”

System must also include the following applicable sentences:

“We failed to conduct the required assessment.”

“We failed to correct all identified sanitary defects that were found during the assessment that we conducted.”


40 CFR 141 Appendix B to Subpart Q –1e

TT Violations (Assessment Triggered By Presence Of Total Coliform)

Tie

r 2

“Coliforms are bacteria that are naturally present in the environment and are used as an indicator that other, potentially harmful, waterborne pathogens may be present or that a potential pathway exists through which contamination may enter the drinking water distribution system. We found coliforms indicating the need to look for potential problems in water treatment or distribution. When this occurs, we are required to conduct assessments to identify problems and to correct any problems that are found.”

System must also include the following sentences:

“We failed to conduct the required assessment.”

“We failed to correct all identified sanitary defects that were found during the assessment that we conducted.”


40 CFR 141.205(d)(2) & Appendix B to Subpart Q –1h

TT Violations (Seasonal Systems)

Tie

r 2

Failure to monitor for total coliforms or E. coli prior to serving water to the public: “We are required to monitor your drinking water for specific contaminants on a regular basis. Results of regular monitoring are an indicator of whether or not your drinking water meets health standards. During [compliance period], we ‘did not monitor or test’ or ‘did not complete all monitoring or testing’ for [contaminant(s)], and therefore cannot be sure of the quality of your drinking water during that time.”

Failure to complete other actions: Appropriate standard content elements in 40 CFR 141.205(a).

156

Consumer Confidence Reports (CCR)

• CWS must report

– Until March 31, 2016

• Total coliform, fecal coliform & E. coli: number or percentage of positive results

– Starting April 1, 2016

• E. coli: number of positive results

• Level 1 or Level 2 assessment language

40 CFR 141.153(c)(4); & 141.153(d)(4)(vii), (viii), & (x)

Updated Final

157

CCR – Case Specific (cont.)

• CCR elements depend on the following case or violation: – Case 1: For systems required to comply with L1 and L2

assessment (not due to an E. coli MCL violation) requirements

– Case 2: For systems required to comply with the L2 assessment requirement due to an E. coli MCL violation

– Case 3: For systems that detected E. coli and have violated the EC MCL

– Case 4: For systems that detected E. coli but did not violate the E. Coli MCL

• Note: Definitions for Level 1 and Level 2 assessments for cases 1 and 2 above

40 CFR 141.153(h)(7)(i), (ii), (iii), & (iv)

CCR Requirements – Case 1

141.153(c)(4) & 141.153(h)(7)(i)

Case 1: L1 & L2 Assessments NOT due to E. coli MCL Violation

14

1.1

53

(c)(

4),

14

1.1

53

(h)(

7)(

i) Systems must include in CCR:

1. Definition of Level 1 and/or Level 2 assessment 2. Health effects language for total coliforms 3. Number of Level 1 assessments required, number of Level 1

assessments completed, number of corrective actions required, and number of corrective actions completed

4. Number of Level 2 assessments required, number of Level 2 assessments completed, number of corrective actions required, and number of corrective actions completed

5. For systems that fail to complete all required assessments or correct all identified sanitary defects, the cause of the TT violation

40 CFR 141.153(c)(4)(i)-(ii)

Case 1: L1 Assessment and L2 Assessment not due to E. coli MCL Violation

Definitions

1

“Level 1 assessment: A Level 1 assessment is a study of the water system to identify potential problems and determine (if possible) why total coliform bacteria have been found in our water system. Level 2 assessment: A Level 2 assessment is a very detailed study of the water system to identify potential problems and determine (if possible) why an E. coli MCL violation has occurred and/or why total coliform bacteria have been found in our water system. “

CCR Requirements – Case 1 (cont.)

40 CFR 141.153(h)(7)(i)(A)



2

“Coliforms are bacteria that are naturally present in the environment and are used as an indicator that other, potentially harmful, waterborne pathogens may be present or that a potential pathway exists through which contamination may enter the drinking water distribution system. We found coliform indicating the need to look for potential problems in water treatment or distribution. When this occurs, we are required to conduct assessment(s) to identify problems and to correct any problems that were found during these assessments.”


40 CFR 141.153(h)(7)(i)(B)-(C)


Results

3

“During the past year we were required to conduct ___ Level 1 assessment(s). ___ Level 1 assessment(s) were completed. In addition, we were required to take ___ corrective actions and we completed ___ of these actions.”

4

“During the past year ___ Level 2 assessments were required to be completed for our water system. ___ Level 2 assessments were completed. In addition, we were required to take ___ corrective actions and we completed ___ of these actions.”


40 CFR 141.153(h)(7)(i)(D)


Failures

5

For systems that have a TT violation for failing to complete all the required assessments or corrective actions, include one or both of the following statements, as appropriate: •“During the past year we failed to conduct all of the required assessment(s).” •“During the past year we failed to correct all identified defects that were found during the assessment.”


40 CFR 141.153(h)(7)(ii)

Case 2: L2 Assessment due E. coli MCL Violation

14

1.1

53

(c)(

4)(

ii),

14

1.1

53

(h)(

7)(

ii)

Systems must include in CCR: 1. Definition of Level 2 assessment 2. Health effects language for E. coli 3. Reason for conducting Level 2 assessment (i.e., because of

EC MCL violation), number of corrective actions required, and number of corrective actions completed

4. For systems that fail to complete all required assessments or correct all identified sanitary defects, the cause of the TT violation



Definition

1

Level 2 assessment: A Level 2 assessment is a very detailed study of the water system to identify potential problems and determine (if possible) why an E. coli MCL violation has occurred and/or why total coliform bacteria have been found in our water system.


40 CFR 141.153(c)(4)(ii)



2

“E. coli are bacteria whose presence indicates that the water may be contaminated with human or animal wastes. Human pathogens in these wastes can cause short-term effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. They may pose a greater health risk for infants, young children, the elderly, and people with severely compromised immune systems. We found E. coli bacteria, indicating the need to look for potential problems in water treatment or distribution. When this occurs, we are required to conduct assessment(s) to identify problems and to correct any problems that were found during these assessments.”


40 CFR 141.153(h)(7)(ii)(A)


Results

3

Reason for conducting Level 2 assessment: “We were required to complete a Level 2 assessment because we found E. coli in our water system. In addition, we were required to take [INSERT NUMBER OF CORRECTIVE ACTIONS] corrective actions and we completed [INSERT NUMBER OF CORRECTIVE ACTIONS] of these actions.”


40 CFR 141.153(h)(7)(ii)(B)


Failures

4

For systems that have a TT violation for failing to complete all the required assessments or corrective actions, include one or both of the following statements, as appropriate: • “We failed to conduct the required assessment.” • “We failed to correct all sanitary defects that were identified during the assessment that we conducted.”


40 CFR 141.153(h)(7)(ii)(C)


40 CFR 141.153(h)(7)(iii)

Case 3: E. coli Detected and E. coli MCL Violation

14

1.1

53

(h)(

7)(

iii)

Systems must include in CCR: 1. Completed table required by 141.153(d)(4) – MCL, MCLG +

Health Effects 2. Reason(s) for non-compliance

• “We had an EC+ repeat sample following a TC+ routine sample.”

• “We had a TC+ repeat sample following an EC+ routine sample.”

• “We failed to take all required repeat samples following an EC+ routine sample.”

• “We failed to test for E. coli when any repeat sample tests positive for total coliform.”

Updated Final


40 CFR 141.153(h)(7)(iv)

Case 4: E. coli Detected but no E. coli MCL Violation

14

1.1

53

(h)(

7)(

iv)

Systems must include in CCR: 1. Must complete table required by 141.153(d)(4) 2. May include statement that explains that although the system

has detected E. coli, they are not in violation of the E. coli MCL.

170


171


When does your state/EPA Regional Direct

Implementation RTCR team intend on

implementing all of the RTCR provisions?

A. Between Jan 1, 2014 – Dec 31, 2014

B. Between Jan 1, 2015 – Dec 31, 2015

C. Between Jan 1, 2016 – Dec 31, 2016

D. Between Jan 1, 2017 – Dec 31, 2017

E. After Jan 1, 2018

172

Other Rule Aspects

173

Associated SWTRs Requirements

• Subpart H systems that are unfiltered could lose unfiltered status based on RTCR monitoring results

– Criteria for avoiding filtration

• Eliminated the TC+ MCL

• Added EC+ MCL

• Distribution system monitoring for detectable residual under SWTR

– No change

– Always take a sample at the same time & place as TC sample (routine & repeat)

40 CFR 141.856(c); 141.857(c); & 141.74(b)(6)(i)

174

Unfiltered Subpart H Systems

• Must conduct monthly routine RTCR monitoring – Must provide filtration if PWS is not in compliance

in at least 11 of 12 previous months: • With E. coli MCL

• Coliform TT requirement

• Must also collect at least one additional TC sample (near first service connection) each day that turbidity exceeds 1 NTU – Must collect sample within 24 hours of

exceedance

– Must use sample as part of RTCR compliance determination

40 CFR 141.71(b); 141.856(c); & 141.857(c)

175

Variances & Exemptions

• EPA is not allowing variances or exemptions

to the E. coli MCL

• EPA is eliminating the variance provision that

allows a system to demonstrate to the state

the violation of MCL is due to biofilm & not

other contamination

40 CFR 141.4(a)-(b)

176

Consecutive Systems

• Consecutive systems must monitor for TC

based on:

– Population served by the consecutive system

– Source type of the wholesale system

177


178


TRUE OR FALSE: Unfiltered Subpart H PWSs must

collect at least one total coliform sample near

first service connection each day that turbidity

exceeds 1 NTU.

A. True

B. False

Updated Final

179


TRUE OR FALSE: Unfiltered Subpart H PWSs must

collect at least one total coliform sample near

first service connection each day that turbidity

exceeds 1 NTU.

A. True

B. False

Updated Final

180

Summary

Sampling Plan

40 CFR 141.853(a)(1)

TCR RTCR

Systems must collect samples that are representative of water throughout the distribution system according to a written sample siting plan

Systems must develop a written sample siting plan that identifies sampling sites & a sample collection schedule that are representative of water throughout the distribution system, no later than March 31, 2016

Sites may include a customer’s premise, dedicated sampling station or other designated compliance sampling station

Routine, repeat & GWR (if the system is subject to the rule) sampling sites must be reflected in the plan

Plans are subject to state review & revision

Plans are subject to state review & revision

Seasonal Systems

TCR RTCR

Seasonal PWS has the same requirements as other systems of the same size & type

All seasonal PWSs must demonstrate (certify) completion of a state-approved start-up procedure

Routine (baseline) monitoring is monthly.

State may exempt seasonal system from requirements (e.g., start-up procedure) if the entire distribution system remains pressurized

40 CFR 141.856(a)(4) & 141.857(a)(4)

Routine Monitoring Frequency (Baseline)

TCR RTCR

PWS ≤1,000 : 1 sample per month Same as current TCR PWS >1,000: monthly based on

population • Seasonal systems ≤1,000: 1

sample per month • Seasonal systems >1,000:

monthly based on population

Seasonal systems monitor based on the size & type of system as identified above

40 CFR 141.856(a)(4) & (b); & 141.857(a)(4) & (b) Updated Final

Repeat Monitoring – # of Samples

TCR RTCR

PWS serving ≤1,000: 4 repeat samples for every TC+ routine sample

• All PWSs must take 3 repeat samples for every TC+ routine sample regardless of whether PWS has already triggered an assessment

• Also must take additional repeats for TC+ repeat samples until TT trigger (including EC MCL) reached

PWS serving >1,000: 3 repeat samples for every TC+ routine sample

40 CFR 141.21(b) & 141.858(a)

Repeat Monitoring – Locations

TCR RTCR

Repeat samples must be collected from the original TC+ site, at least one at a tap within 5 service connections upstream, & at least one at a tap within 5 service connections downstream

PWS can collect repeat samples using the same procedure as in the TCR, or

PWS can specify in their sample siting plan either fixed alternative locations or criteria for selecting sites on a situational basis via a standard operating procedure

40 CFR 141.853(a)(5)

Additional Routine Monitoring

40 CFR 141.21(b)(5); 141.856(b); & 141.857(b)

TCR RTCR

PWS taking < 5 routine samples per month (PWS serving ≤4,100)

• Must take at least 5 routine samples in the month after a TC+ sample

No longer a requirement for systems that monitor at least monthly

PWSs taking samples less frequently than once per month (i.e., quarterly or annually)

• Must take at least 3 routine samples in a month after a TC+ sample

Updated Final

Acute MCL Violation

40 CFR 141.63 & 141.860(a)

TCR RTCR

Fecal coliform-positive repeat sample

EC+ repeat sample following a TC+ routine sample

EC+ repeat sample TC+ repeat sample following an EC+ routine sample

TC+ repeat sample following a fecal coliform-positive or EC+ routine sample

Fails to take all required repeat samples following an EC+ routine sample

Fails to test for E. coli when any repeat sample tests positive for total coliform

MCL & TT Violations & PN

40 CFR 141.63(b) & (d); 141.202; 141.203; & 141.860(a)-(b)

TCR RTCR

Violation of TC MCL when fecal coliform or E. coli are present – Tier 1 PN PWS must notify state re: single EC/FC+ result

Violation of E. coli MCL – Tier 1 PN

PWS must notify state re: single EC+ result

Monthly TC MCL violation is dropped – triggers assessment & corrective action instead

A TT violation occurs when a PWS fails to conduct required assessment or corrective action – Tier 2 PN

Violation of monthly TC MCL – Tier 2 PN

A TT violation occurs when a seasonal system fails to complete a state-approved start-up procedure prior to serving water to the public – Tier 2 PN

Monitoring (M) & Reporting (R) Violations & PN

TCR RTCR

M&R violation Tier 3 PN

• Monitoring violations and reporting violations will be tracked separately – Both require Tier 3 PN

• Newly specified M&R violations: ‒ (M) Failure to take every required routine or additional

routine sample in a compliance period ‒ (M) Failure to analyze for E. coli following a TC+ routine

sample ‒ (R) Failure to submit a monitoring report or completed

assessment form after monitoring or conducting assessment correctly/timely

‒ (R) Failure to notify the state following an E. coli+ sample ‒ (R) Failure to submit certification of completion of state-

approved start-up procedure by a seasonal system

40 CFR 141.204 & 141.860(c)-(d)

PN & CCR Rules – Health Effects Language

TCR RTCR

Mandatory health effects language for TC & fecal coliforms/E. coli

TC health effects language changed to reflect nature of TC as an indicator

The health effects language for fecal coliforms/E. coli has been replaced with health effects language for E. coli only

40 CFR 141, Appendix B to Subpart Q

CCR Language

40 CFR 141.153(d)(4) & 141.153(h)(7)

TCR RTCR

Information related to highest monthly TC results (number or percentage) & the total number of fecal coliforms/EC+ samples

Information on the total number of EC+ samples

Information about the number of assessments required & corrective actions taken, and, if appropriate, the number of assessments & corrective actions not completed

Updated Final

Analytical Methods

40 CFR 141.852

TCR RTCR

PWS must conduct TC analysis in accordance with the methods listed in 40 CFR 141.21(f)

Changes to methods, include:

• Change in holding time definition

• Requiring de-chlorination agent

• Requiring autoclaving of MF funnel

Revised & clarified the methods table (40 CFR 141.852)

Variances, Exemptions & Best Available Technology (BAT)

40 CFR 142.63(b) & (e)

TCR RTCR

Variances or exemptions may not be granted for TC MCLs except for persistent growth of TC (biofilm)

Variances or exemptions no longer needed since TC MCL is no longer effective

Variances or exemptions may not be granted for E. coli MCLs

Variances or exemptions may not be granted for E. coli MCL

BAT includes proper maintenance of the distribution system

• Cross connection control added to the BAT distribution system maintenance activities

• Updated filtration (SW) & disinfection (SW & GW) BAT to include IESWTR, LT1ESWTR, LT2ESWTR & GWR

194

Frequently Asked Question

What if a system conducts a required assessment, sets a timeline for corrective action years into the future, which is accepted by the primacy agency, but triggers additional assessments before the corrective action can be completed?

ANSWER: The system would incur a Level 1 or Level 2 assessment for each triggered event and must correct any additional sanitary defects. If the system discovers that the contamination continues to be caused by the original triggering event, the system can perform interim measures that ensure the delivery of safe water.

Clarification Slide

195


Does each TC+ routine sample need 3 repeat

samples?

ANSWER: Yes, each TC+ routine sample needs

3 repeat samples regardless of whether an

assessment has been triggered.

Clarification Slide

196


Are consecutive (purchased) systems that receive

SW, purchased GWUDI, or systems that purchase

SW/GWUDI blended sources required to monitor

monthly for total coliforms under the RTCR?

ANSWER: Yes, any system that has a SW, GWUDI,

SW/GWUDI blended source(s) are required to monitor on a monthly basis for total coliform.

These systems are considered SW systems for

purposes of RTCR coliform monitoring.

Clarification Slide

197

RTCR Technical Corrections

Planned for Publication in

Federal Register

(Total=6)

198

RTCR Technical Corrections Planned for Publication in Federal Register

1. Incorrect cross-reference

§141.861 REPORTING AND RECORDKEEPING

(a) ***

(b) Recordkeeping. (1) The system must maintain any assessment form, regardless of who conducts the assessment, and documentation of corrective actions completed as a result of those assessments, or other available summary documentation of the sanitary defects and corrective actions taken under §141.858 §141.859 for State review. This record must be maintained by the system for a period not less than five years after completion of the assessment or corrective action.

(2) ***

NOTE: Suggested language (in yellow) may change in FR.

199

RTCR Technical Corrections Planned for Publication in Federal Register

2. Incomplete list of items to be included in state

primacy application

142.16 SPECIAL PRIMACY REQUIREMENTS

(a) ***

***

(q) Requirements for States to adopt 40 CFR part 141 subpart Y – Revised Total Coliform Rule

(1) ***

(2) The State’s application for primacy for subpart Y must include a written description for each provision included in paragraphs (q)(2)(i) through (viii) (ix) of this section.

***


200

RTCR Technical Corrections Planned for Publication in Federal Register (cont.)

3. Vague/confusing language

142.16 SPECIAL PRIMACY APPLICATIONS

(a) ***

***

(q) Requirements for States to adopt 40 CFR part 141 subpart Y – Revised Total Coliform Rule

***

(2) ***

(ii) Reduced Monitoring Criteria – An indication of whether the State will adopt the reduced

monitoring provisions of 40 CFR part 141, subpart Y. If the State adopts the reduced

monitoring provisions, it must describe the specific types or categories of water systems

that will be covered by reduced monitoring and whether the State will use all or a

reduced set of the optional criteria. For each of the reduced monitoring criteria, both

mandatory and optional, the State must describe how the criteria will be evaluated to

determine when systems qualify.

NOTE: “Optional” criteria refers to criteria found in 141.854(h)(2) and 141.855(d)(1)(iii) of this title, where the State selects at least one.


201


3. Vague/confusing language

142.16 SPECIAL PRIMACY APPLICATIONS

a) ***

***

(q) Requirements for States to adopt 40 CFR part 141 subpart Y – Revised Total Coliform Rule ***

(2) ***

(ii) Reduced Monitoring Criteria – An indication of whether the State will adopt the reduced monitoring provisions of 40 CFR part 141, subpart Y. If the State adopts the reduced monitoring provisions, it must describe the specific types or categories of water systems that will be covered by reduced monitoring and whether the State will use all or a reduced set of the optional criteria specified in §§ 141.854(h)(2) and 141.855(d)(1)(iii) of this Title. For each of the reduced monitoring criteria, both mandatory and optional, the State must describe how the criteria will be evaluated to determine when systems qualify.



40 CFR Appendix A to Subpart Q

4. Clarify table in Appendix A to Subpart Q (Public Notification of Drinking Water

Violations)

Contaminant MCL/MRDL/TT violations2 Monitoring, testing & reporting procedure

violations

PN Tier required Citation


I. Violations of National Primary Drinking Water Regulations (NPDWR):3

A. Microbiological Contaminants

1.a Total coliform bacteria † 2 141.63(a) 3 141.21(a)-(e)

1.b Total coliform (Monitoring or TT violations resulting from failure to perform assessments or corrective actions, monitoring violations, and reporting violations) ‡

2 141.860(b)(1) 3 141.860(c)(1) 141.860(d)(1)

1.c Seasonal system failure to follow State-approved start-up plan prior to serving water to the public or failure to provide certification to State.‡

2 141.860(b)(2) 3 141.860(d)(3)



40 CFR Appendix A to Subpart Q

Contaminant MCL/MRDL/TT violations2 Monitoring, testing & reporting procedure

violations



2.a Fecal coliform/E. coli † 1 141.63(b) 41,3 141.21(e)

2.b E. coli (MCL, monitoring, and reporting violations)‡

1 141.860(a) 3 141.860(c)(2) 141.860(d)(1) 141.860(d)(2)

2.c E. coli (TT violations resulting from failure to perform level 2 Assessments or corrective action) ‡

2 141.860(b)(1)

4. Clarify table in Appendix A to Subpart Q (Public Notification of Drinking Water

Violations)



5. OFR mistake: citation for an analytical method in the

wrong column

40 CFR 141.852(a)(5)

Organism Methodology Category

Method 1 Citation 1

Total Coliforms *** Enzyme

Substrate Methods

Colilert® Standard Methods

Online 9223 B-97 2, 5

Standard Methods 9223 B (20th ed.; 21st

ed.) 2, 5 Standard Methods

Online 9223 B-97 2, 5

*** ***


205


6. Imperfect numbering

141.855 ROUTINE MONITORING REQUIREMENTS FOR COMMUNITY WATER SYSTEMS SERVING 1,000 OR FEWER PEOPLE USING ONLY GROUND WATER (a) ***

(d) Criteria for reduced monitoring.

(1) ***

(2) Reserved

(e) ***


206

Questions Regarding the RTCR?

US EPA Headquarters Cindy Mack, RTCR Rule

Manager Email: [email protected] Phone Number: 202-564-6280 TCR Website:

http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/index.cfm RTCR Website: http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/regulation_r

evisions.cfm The Feb. 2013 Final RTCR can be found at this website, along

with the RTCR Quick Reference Guide (QRG).

Nancy Ho, Environmental Scientist

Email: [email protected] Phone Number: 202-564-3896

mailto:[email protected]



http://water.epa.gov/lawsregs/rulesregs/sdwa/tcr/index.cfm


US EPA RTCR Regional Technical Contacts

Region Staff Email

1 Denise Springborg [email protected] 1 Kevin Reilly [email protected] 2 Michael Lowy [email protected] 3 Kelly Moran [email protected] 3 Patti-Kay Wisniewski [email protected] 4 Pamela Riley [email protected] 4 Brian Smith [email protected] 4 Dale Froneberger [email protected] 5 Miguel Del Toral [email protected]

US EPA RTCR Regional Technical Contacts (cont.)

Region Staff Email

6 Andrew Waite [email protected]

7 Robert Dunlevy [email protected]

7 Stan Calow [email protected]

8 Breann Bockstahler [email protected]

8 Robert Clement [email protected]

9 Andrew Sallach [email protected]

9 Bruce Macler [email protected]

10 Cyndi Grafe [email protected]

10 Wendy Marshall [email protected]